Now, the Administration wants to try again. Last week, the U.S. Department of Agriculture (USDA) released a proposed rule change: “Revisions of Categorical Eligibility in the Supplemental Nutrition Assistance Program.” If enacted, this proposed rule will cause undue harm to low- and moderate-income families and add an unnecessary administrative burden to states. States will be forced to reimpose asset limits on SNAP recipients who may have previously been exempted. The USDA should rescind this proposed rule in its entirety and leave the long-standing categorical eligibility options unaffected.

BBCE allows states to seamlessly enroll recipients of Temporary Assistance for Needy Families (TANF) programs such as job preparation or childcare assistance into other benefit programs like SNAP. Essentially, this means that if a family qualifies for one program, then a state can easily enroll that same family in another benefit program without burdening the state or the family with extra paperwork. Currently, over 40 states use the BBCE criteria to help low- and moderate-income Americans receive SNAP assistance.

For more than 20 years, Congress has given states flexibility to adjust savings penalties (otherwise knowns as asset limits) in public assistance programs. In fact, in 2002, Congress gave states even more flexibility by giving them the authority to use BBCE to assess a family’s SNAP eligibility. Since then, states have used both the BBCE criteria and discretion to decide whether to impose savings penalties or to expand SNAP benefits to more low- and moderate-income families.

Asset tests hurt families’ economic mobility, deter families from applying for needed support and may drive families to spend-down their savings. When families spend their modest savings to qualify for assistance, this leaves them more susceptible to unforeseen financial shocks such as a job loss or medical expense. These unexpected events may upend a family's financial security.

It is shortsighted to limit states’ autonomy to waive asset tests through categorical eligibility. Furthermore, asset tests are a disservice to the imperatives of safety net programs which are designed to promote self-sufficiency and economic mobility. We must preserve access to safety net programs like SNAP because they make up the very first rungs of the ladder of opportunity which is essential to helping low-income households thrive.